6th Floor, 55 Wells Street
London, W1A 3AE
For additional information on Kuvari, please contact Amanda Bedford, Head of Investor Relations by clicking here.
IMPORTANT INFORMATION ABOUT ACCESS TO THIS SITE.
1st January 2023
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2A.5, Kuvari Partners (“the Firm”) is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code (“Code”).
The Code was first published by the FRC in July 2010 and it was updated in September 2012. Subsequently, the FRC published the new UK Stewardship Code 2020 (“2020 Code”), which took effect from 1 January 2020, and consists of 12 Principles for asset managers and asset owners, and six Principles for service providers.
The Code applies on a ‘comply or explain’ basis and is voluntary aiming at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.
The FRC defines ‘stewardship’ as ‘the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.’
The 2020 Code Principles are:
Purpose and governance
Exercising Rights and Responsibilities
Kuvari pursues a fundamental investment strategy across global equity markets with a core focus on Europe, including UK equities. The approach of the Firm in relation to engagement with issuers and their management is determined globally. The Firm takes a consistent approach to engagement with issuers and their management in all of the jurisdictions in which we invest and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. Hence, while the Firm generally supports the objectives that underlie the Code in its investment activities, the Firm has chosen not to commit to the Code.
This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.
For further information on the Firm’s approach contact Padraig Hayes here
Kuvari Partners LLP (‘Kuvari’) is a discretionary portfolio manager/full-scope UK AIFM.
This statement sets out the firm’s approach in meeting the requirements (‘Engagement Policy’) set out in SRD II and summarised in the FCA Handbook under COBS 2.2B.6 in relation to investments in shares traded on a regulated market (a term which extends to a UK regulated market including certain markets situated outside the United Kingdom where the financial instruments dealt in are of a quality comparable to those in a UK regulated market).
Integration of shareholder engagement in investment strategy
Kuvari maintains a dynamic ‘approved list’ of financial instruments which the portfolio managers of Kuvari may select for inclusion in a portfolio as suitable for a particular mandate.
A security will only appear on this approved list after conducting a rigorous analysis of the company concerned – such an analysis may entail the need to directly engage with senior management of that company to discuss finances, future prospects etc.
Monitoring and Dialogue with Investee Companies (Strategy, Financial and Non-Financial Performance Risk, Capital Structure and ESG)
Kuvari’s investment team conducts a number of meetings with the portfolio companies both in person and conference calls. During these meetings we discuss a broad range of issues including but not restricted to strategies for long term growth, capital allocation, financing plans and corporate governance best practices. We also address social and environmental issues, focusing on areas where we believe the greatest areas of concern are. The breadth and depth of our ESG engagement is due to increase as we continue to develop our ESG policy.
The focus is on long term measures and encourage companies to focus on creating the most amount of value for all stakeholders as opposed to short term profit maximisation that endangers the long-term health of the business.
There may be instances when we are of the view that the portfolio companies have room for improvement. In such cases we would initially discuss our concerns directly with management. If management do not provide a satisfactory response or fail to respond to our concerns, we will then assess whether the issue is significant enough to change the investment case. If the issue is deemed significant enough to change the investment case, we would then make a decision whether to continue to hold the company and vote against the measure or to sell our shares in the company entirely.
Exercise of Voting Rights
Any resolution proposed by a material portfolio company which is subject to a shareholders vote will be considered by Kuvari, making use of input from relevant portfolio manager(s) and analyst(s). In arriving at a voting decision Kuvari will arrive at one that it is believed will be in the best interests of the portfolios (‘Best interests rule’ in COBS 2.1). The voting decision may well involve abstaining or voting against management if their actions and objectives do not match up with what we believe to be in the best interests of shareholders. Kuvari will provide an annual disclosure which details our voting behaviour except where a particular vote is deemed to be insignificant as to either subject matter e.g. the appointment of directors or as to size.
Cooperation with Other Shareholders
Generally Kuvari does not adopt an activist approach with other shareholders, although the firm remains open to doing so if this would be deemed to be in the best interests of shareholders.
Communication with Relevant Stakeholders of Investee Companies
We do not typically communicate directly with staff - save for those instances identified above (see “Monitoring and Dialogue with Investee Companies”) - customers or suppliers of any portfolio company directly.
Conflicts of Interests
The firm maintains a Conflicts of Interest policy which can be shared upon request. For further details, please contact: Compliance@kuvaripartners.com
IMPORTANT INFORMATION ABOUT ACCESS TO THIS SITE.
Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Kuvari Partners LLP (“we”, “us” OR “the Firm”) and sets out our policies with respect to the collection, sharing and use of personal information. For the purposes of the UK General Data Protection Regulation (‘GDPR’), Kuvari Partners LLP will be the ‘controller’ of the personal data you provide.
What data privacy principles does the Firm adhere to?
How we collect information about you
We may collect personal data about you through:
We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.
Why we collect information about you
We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements. This includes (but not limited to) the UK GDPR, which is retained in the EU law version of the General Data Protection Regulation ((EU) 2016/679) (EU GDPR) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419), and the Data Protection Act 2018, as updated from time to time.
We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.
The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.
What are the consequences of failing to provide your personal information?
As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).
We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.
A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.
The types of personal data we may collect and use
The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).
Do we use automated decision-making processes?
How have I been categorised in accordance with GDPR?
The UK GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:
Do we share your personal information with third parties?
We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:
Purposes of why we may share your personal data include but is not limited to fulfilling our legitimate interests, such as:
Transfers of personal information to countries outside of the European Economic Area (EEA)
Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.
For how long do we keep your personal information?
We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.
The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you.
As regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority).
We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required. Any information that is outside the scope of the requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.
Where does the Firm store my personal data?
The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:
The UK GDPR classes cookie identifiers as a type of ‘online identifier’, meaning that in certain circumstances these will be personal data. To the extent that we collect personal information with the help of Cookies we will process them in accordance with this Privacy Notice.
Cookies used on the Firm’s Website are used to record information necessary for the proper functioning of the Firm’s Website and the products and services offered to you, use monitoring and security.
For more information about cookies, including how to set your internet browser to reject cookies, please go to ICO – Cookies.
What are your rights?
You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:
How to contact us
If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Compliance Officer by email at email@example.com or by writing to Compliance Officer 5th Floor, 55 Wells Street, London, W1A 3AE, United Kingdom.
Complaining to ICO
You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO's Website.
Recording and monitoring of communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of:
Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.
For further information on the Firm’s approach contact Padraig Hayes here
Kuvari Partners LLP’s complaints handling procedure is in line with Financial Conduct Authority’s rules regarding complaints handling. A copy of Kuvari’s Complaints Policy is available upon request, please contact: Compliance@kuvaripartners.com
Complaints may be made to Kuvari by the following means:
By email: Compliance@kuvaripartners.com
In writing addressed to:
6th Floor, 55 Wells Street
A complainant may also be entitled to refer their complaint to the Financial Ombudsman Service (“FOS”). The FOS is a UK agency for arbitrating on complaints between regulated firms and their clients. More information can be found in the Complaints Policy.
The FOS can be contacted at:
Kuvari Partners LLP Public Disclosure Statement (SNI)
1. Overview and Summary
Kuvari is authorised and regulated by the Financial Conduct Authority (“FCA”) as a Collective Portfolio Management Investment Firm (“CPMI”), authorised under UK Alternative Investment Fund Managers Directive (“UK AIFMD”).
As a CPMI firm Kuvari has to maintain regulatory capital and liquidity at all times in compliance with AIFMD and the Investment Firm Prudential Regime (“IFPR”).
The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.
This Public Disclosure Document has been prepared based on the audited financials as at 31 March 2023.
The Firm’s main business activity is the management of AIFs and a number of Managed Accounts.
2. Remuneration arrangements
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).
In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:
Kuvari does not benefit from exceptional government intervention.
Kuvari’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.
Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.
Performance reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment, and
Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.
The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.
The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.
All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.
As an SNI firm and in accordance with MIFIDPRU 8.6.8, Kuvari is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.
For the performance year ending 31 March 2023:
Total fixed remuneration awarded £1,436,000
Total variable remuneration awarded £1,520,835.30
Total remuneration awarded £2,956,835.30